Spain's Deposit Return Deadline of 22 November 2026: Where the SDDR Stands and What Beverage Brands Selling in Spain Should Prepare

What Has Changed for Beverage Packaging in Spain Since Our Spain Overview?

Spanish law now requires a deposit, return and refund system for single-use beverage bottles, cans and beverage cartons. The obligation comes from Article 47 of Royal Decree 1055/2022, triggered because Spain missed its 2023 separate collection target, and the Spanish press dates its start to 22 November 2026.

Our overview of PPWR compliance in Spain covers the general framework; this article reads the deposit rules on the Boletín Oficial del Estado and official pages on 20 October 2026, for brands, importers, distributors and label converters selling in Spain.

Key Facts

• Under Article 47.1 of Royal Decree 1055/2022, producers of single-use plastic bottles of up to 3 litres must set up a deposit, return and refund system within two years once the collection targets are missed, cans and beverage cartons included.
• A report of the Ministry for the Ecological Transition dated November 2024 puts the 2023 separate collection rate of single-use plastic beverage bottles at 41.3%, against a 70% target.
• Under Article 47.4 of Royal Decree 1055/2022, the deposit is set freely by the producer responsibility systems at 10 euro cents or more per beverage container.
• Portugal's Volta deposit system has operated since 10 April 2026, with a 10-cent deposit, according to the Portuguese Directorate-General for Economic Activities.
• Under Article 50(1) of Regulation (EU) 2025/40, Member States take measures to ensure the separate collection of at least 90% by weight of single-use plastic beverage bottles and metal beverage containers of up to three litres by 1 January 2029.
• Under Article 6(1), all packaging placed on the market shall be recyclable, an obligation that has applied since 12 August 2026, transport packaging included.

What Does Spanish Law Require, and Where Does the 22 November 2026 Date Come From?

Article 59.2 of Law 7/2022 and Article 47 of Royal Decree 1055/2022 require a nationwide deposit, return and refund system within two years once Spain misses its 2023 or 2027 bottle collection target. Article 47.2 counts the two years from the notification of non-compliance to the producer responsibility systems.

The SDDR is the Spanish deposit, return and refund system for beverage packaging, named in the law as the sistema de depósito, devolución y retorno. Under Article 59.1 of Law 7/2022, separate collection of single-use plastic bottles must reach 70% by weight in 2023, 77% in 2025, 85% in 2027 and 90% in 2029.

Article 47.1 of Royal Decree 1055/2022 covers water, juices, nectars, soft, energy, isotonic and alcoholic drinks in single-use plastic bottles of up to 3 litres, plus cans and beverage cartons for these products. Under Article 47.2, the producers then have six months from the notification to file an application for authorisation, and two years from the notification to start the system.

The date of 22 November 2026 is the one cited by El Salto and Xataka. We did not find the notification itself on an official page, so the exact day rests on the press, while the two-year rule rests on the Royal Decree.

Why Was the Spanish Deposit Obligation Triggered?

The Spanish deposit obligation was triggered because separate collection of single-use plastic beverage bottles reached 41.3% in 2023, according to the Ministry for the Ecological Transition, below the 70% target of Article 59.1 of Law 7/2022. The ministry's November 2024 report concludes that a deposit system must follow within two years.

The report counts 214,039 tonnes of these bottles placed on the Spanish market in 2023, against 74,482 tonnes collected by local authorities and 14,017 tonnes through private or complementary collection.

Who Will Operate the Spanish SDDR, and Where Do the Authorisations Stand?

On 20 October 2026, no authorised operator of the Spanish SDDR appears on the official pages we read. Applications for a collective producer responsibility system go to the autonomous community where the system has its registered office, and the SDDR applications are before the Community of Madrid, whose decision is still awaited.

The Community of Madrid's packaging page, updated on 28 August 2026, states that an application goes to the region of the registered office under Article 50.2 of Law 7/2022, and that the Comisión de Coordinación en materia de residuos assesses it. A Madrid transparency register entry records a ministry letter of 26 August 2025 on the processing of the deposit system applications.

According to Foodretail on 25 September 2026, Asociación SDDR para España, Procircular and Ecoembes were still awaiting the Madrid decision; El Salto also names CorePET among the applicants. On 15 October 2026, Qué! reported that the Madrid files had still not been processed. Royal Decree 806/2026 of 5 October also calls general elections for 29 November 2026, according to the National Statistics Institute.

How Does the Deposit Flow Work Under Article 47 of Royal Decree 1055/2022?

Under Article 47.4 of Royal Decree 1055/2022, the producer pays the deposit first for each beverage container it places on the Spanish market, each sales channel pays it on to the producer and passes it to the consumer, and the consumer recovers the deposit on returning the empty container.

What Should Beverage Brands and Importers Selling in Spain Prepare Now?

A beverage brand or importer selling bottled water, juices, soft drinks or alcoholic drinks in single-use plastic bottles, cans or cartons in Spain can prepare four things now: which system to join, how each container is marked, how deposits flow through its invoices, and which data the system register asks for.

1. Membership. Under Article 47.1, the obligation is met through individual or collective producer responsibility systems. With no operator authorised yet, list the containers in scope and follow the Madrid decision.
2. Marking. Article 47.7 requires the packaging to be distinguished so that the consumer knows it carries a refundable deposit and so that the marking works against fraud, and Article 47.8 lets the system require producers to apply it. The text sets no design: plan artwork changes without committing one. Label and sleeve converters are in the same chain; see deposit return scheme labelling for converters.
3. Deposit flows. Under Article 47.4, distributors and retailers pay the deposit to the producer at the time of the transaction and pass it on to the consumer.
4. Data. Under Article 47.8, the system keeps a register of its producers and of the beverages covered, with the number and characteristics of containers placed on the market.

The PPWR rules on the same bottles and cans still apply; see our PPWR guide for the beverage industry.

How Does Portugal's Volta System Work Since 10 April 2026?

Portugal's Volta deposit system has operated since 10 April 2026 for non-reusable primary beverage packaging of plastic, ferrous metal or aluminium under 3 litres, with a deposit of 10 cents refunded on return, according to the Portuguese Directorate-General for Economic Activities.

The directorate states that packaging with and without the Volta symbol could be sold side by side until 9 August 2026, and that only packaging bearing the symbol is covered and refunded. The Portuguese Government names SDR Portugal, a non-profit entity, as the system manager, financed by producers and packers under extended producer responsibility.

For a brand selling in both countries on 20 October 2026, Portugal has one operator, a symbol and a return network; Spain has a legal obligation, several candidates and no operator yet.

How Does Article 50 of the PPWR Relate to the Spanish and Portuguese Systems?

Article 50 of Regulation (EU) 2025/40 requires Member States to set up deposit and return systems for single-use plastic beverage bottles and metal beverage containers of up to three litres, with a deposit charged at the point of sale, to reach 90% separate collection by 1 January 2029; the Spanish SDDR and Portugal's Volta are national answers.

A deposit and return system is a system in which a deposit is charged to the end user when purchasing a product covered by that system, and redeemed when the packaging is returned through a channel authorised by the national authorities, under Article 3(1)(62). Under Article 50(5), a Member State may be exempt if its separate collection rate reaches 80% by weight in 2026 and it notifies the Commission with an implementation plan by 1 January 2028. The last official Spanish figure we read, 41.3% for 2023, is far below that threshold, though it is not the 2026 figure.

Under Article 50(4), the deposit obligation does not cover packaging for wine products, spirit drinks under CN heading 2208, or milk and milk products. Under Article 50(11), systems set up under Article 50(2) after the Regulation entered into force meet the minimum requirements of Annex X by 1 January 2029. Annex X asks for a single system operator or, where there are several, coordination measures by the Member State, a non-profit and independent operator, and clearly labelled deposit packaging. Under Article 12(1), in the paragraph that sets the harmonised label from 12 August 2028 or 24 months after the implementing acts, whichever is the latest, packaging subject to an Article 50(1) deposit system shall be marked with a clear and unambiguous label and may carry a harmonised colour label.

Spain's ministry notes, in a clarifying note of 19 May 2026, that the European Regulation prevails over Royal Decree 1055/2022 where they conflict, and that the Royal Decree governs what the Regulation leaves open until a new national text replaces it. See also which PPWR obligations apply today.

What Remains Undecided on 20 October 2026?

On 20 October 2026, four points of the Spanish SDDR remain undecided: who operates the system, the start date in practice, the design of the Spanish deposit mark, and the content of the new Royal Decree on packaging that the ministry is preparing.

• Operator. No authorisation decision of the Community of Madrid was found. With several candidates, Annex X, point (a), of the PPWR calls for coordination between operators.
• Start date. Qué! reported on 11 October 2026 that operators expect a start at the end of 2028 or the beginning of 2029; no official postponement was found.
• Mark and deposit. Article 47 sets a 10-cent floor and a marking duty; the system sets the rest.
• New Royal Decree. The ministry held a prior public consultation from 5 May to 5 June 2025; on 20 October 2026, the consolidated text of Royal Decree 1055/2022 on the BOE still shows only its initial version.

What Does the Referential Not Confirm?

Our dated PPWR referential (baseline reviewed 3 October 2026) confirms two statements here: the recyclability obligation of Article 6(1) and, in the FAQ, the scope of Article 2(1). Its claim check found no match for the points below, read on the linked text.

• Articles 3(1)(62), 12(1), 50(1), 50(2), 50(4), 50(5), 50(9), 50(11) and Annex X, read on the Official Journal text, not recorded in our referential.
• Every Spanish and Portuguese statement, read on the BOE, the ministry, the Community of Madrid, the National Statistics Institute and the Portuguese pages on 20 October 2026. Nothing here is legal advice.
• Not confirmed on an official page: the day of 22 November 2026 and the list of applicants, which rest on the press, named in each sentence.

Frequently Asked Questions

Does the Spanish SDDR cover glass bottles?

No. Article 47.1 of Royal Decree 1055/2022 covers single-use plastic bottles of up to 3 litres, plus cans and beverage cartons for the same drinks.

Does the deposit change the PPWR obligations on a bottle or a can?

Mostly not. Regulation (EU) 2025/40 applies to all packaging, regardless of material, whether household, commercial or industrial, under Article 2(1). One difference is labelling: under Article 12(1), the harmonised material label does not apply to packaging subject to a deposit and return system.

What collection rate must the Spanish system reach?

Under Article 47.3 of Royal Decree 1055/2022, when the 2023 target is missed, the systems must reach separate collection of at least 90% by weight of the packaging in the system within two years of its start.

How PPWR Connect Helps

PPWR Connect keeps each packaging reference with its components, materials and markets, and a market can be an EU Member State such as Spain or Portugal. Packaging configurations and dated packaging versions model the variants of one SKU, and the shared component library defines a cap, label or liner once and shows where each part is used. Since 15 October 2026, the action center groups actions by packaging, and Mark done records who did it and when. PPWR Connect is software, not a producer responsibility organisation, a deposit system operator or a legal adviser, and it does not register a producer with a deposit and return system. Start with our PPWR compliance software or the PPWR readiness assessment.

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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.